Welcome to our monthly column featuring CONN-OSHA experts answering some of the most commonly asked questions from CBIA member companies.

Most of the responses from Catherine Zinsser, a CONN-OSHA occupational safety training specialist, will be on recordkeeping since that is the focus of most questions she fields.

But if you'd like to ask her a question on another topic, please email CBIA's Phillip Montgomery.

He will treat all questions confidentially and never share any identifying company information with CONN-OSHA or anyone else.


Q: An employee experienced an injury or illness in the work environment before they clocked in for the day. Is the case considered work-related even if that employee was not officially on the clock for pay purposes? 

A: Yes. For purposes of OSHA recordkeeping, injuries and illnesses occurring in the work environment are considered work-related. 

Punching in and out with a time clock (or signing in and out) does not affect the outcome for determining work-relatedness. 

If the employee experienced a work-related injury or illness, and it meets one or more of the general recording criteria under section 1904.7, it must be entered on the employer's OSHA 300 log.


Q: An employee has a work-related shoulder injury resulting in days of restricted work activity. While working on restricted duty, the employee sustains a foot injury which results in a different work restriction. How would the employer record these cases?

A: For purposes of OSHA recordkeeping, the employer would stop the count of the days of restricted work activity due to the first case, the shoulder injury, and enter the foot injury as a new case and record the number of restricted work days. 

If the restriction related to the second case, the foot injury, is lifted and the employee is still subject to the restriction related to their shoulder injury, the employer must resume the count of days of restricted work activity for that case.


Q: An employee was exiting the cafeteria at work and slipped and fell after stopping to clean up spilled salad dressing. Would this be considered work-related as they were not in the scope of their duties? They have a desk job and were just helping.

A: The case is work-related. Injuries and illnesses occurring in the work environment are considered work-related unless they meet one of the exceptions listed under 1904.5(b) (2). 

The work environment includes the establishment and other locations where one or more employees are working or are present as a condition of their employment. 

OSHA's no-fault recordkeeping system requires recording work-related injuries and illnesses from events or exposures that occur in the work environment, regardless of the level of employer control or non-control involved.


Catherine Zinsser will host a webinar Jan. 18 as part of the CONN-OSHA Breakfast Roundtable Series on OSHA Injury and Illness Recordkeeping.


For more information, contact CBIA's Phillip Montgomery (860.244.1982).